Legalize / European Union / Regulation

Council Regulation (EU) No 36/2012 of 18 January 2012 concerning restrictive measures in view of the situation in Syria and repealing Regulation (EU) No 442/2011

Type Regulation

Publication 2012-01-18

Last updated 2025-09-24

State In force

Department Council of the European Union

Source EUR-Lex

articles 39

Reform history JSON API

B. Entities

	Name	Identifying information	Reasons	Date of listing

1.	Bena Properties	Cham Holding Building, Daraa Highway, Ashrafiyat Sahnaya Rif Dimashq, Syria, P.O. Box 9525	Held by Rami Makhlouf. Syria’s largest real estate company and the real estate and investment arm of Cham Holding; provides funding to the former al-Assad regime.	23.6.2011
2.	Al Mashreq Investment Fund (AMIF) (a.k.a. Sunduq Al Mashrek Al Istithmari)	P.O. Box 108, Damascus, Syria; Tel: +963 112110059 / 963 112110043; Fax: +963 933333149	Held by Rami Makhlouf; provides funding to the former al-Assad regime.	23.6.2011
3.	Hamcho International (a.k.a. Hamsho International Group)	Baghdad Street, P.O. Box 8254, Damascus, Syria; Tel: +963 112316675; Fax: +963 112318875; Website: www.hamshointl.com; E-mail: info@hamshointl.com and hamshogroup@yahoo.com	Hamcho International is a large Syrian holding company owned by Mohammed Hamcho. Hamcho International benefits from and provides support to the former al-Assad regime and is associated with a person benefiting from and supporting the former al-Assad regime.	27.1.2015
4.	Military Housing Establishment (a.k.a. MILIHOUSE)		Public works company controlled by Riyad Shalish and Ministry of Defence; provides funding to the former al-Assad regime.	23.6.2011
5.	Political Security Directorate		Syrian government agency directly involved in repression under the former al-Assad regime.	23.8.2011
6.	General Intelligence Directorate		Syrian government agency directly involved in repression under the former al-Assad regime.	23.8.2011
7.	Military Intelligence Directorate		Syrian government agency directly involved in repression under the former al-Assad regime.	23.8.2011
8.	Air Force Intelligence Agency		Syrian government agency directly involved in repression under the former al-Assad regime.	23.8.2011
9.	IRGC Qods Force (a.k.a. Quds Force)	Teheran, Iran	The Qods (or Quds) Force is a specialist arm of the Iranian Islamic Revolutionary Guard Corps (IRGC). The Qods Force is involved in providing equipment and support to help the former al-Assad regime suppress protests in Syria. The Qods Force has provided technical assistance, equipment and support to the Syrian security services to repress civilian protest movements.	23.8.2011
10.	Mada Transport	Subsidiary of Cham Holding (Sehanya Dara’a Highway, P.O. Box 9525); Tel: +963 11 99 62	Economic entity financing the former al-Assad regime.	2.9.2011
11.	Cham Investment Group	Subsidiary of Cham Holding (Sehanya Dara’a Highway, P.O. Box 9525); Tel: +963 11 99 62	Economic entity financing the former al-Assad regime.	2.9.2011
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13.	Addounia TV (a.k.a. Dounia TV)	Tel: +963 11 5667274; +963 11 5667271; Fax: +963 11 5667272; Website: http://www.addounia.tv; Relatives/business associates/entities or partners/links: SAMA TV (sister company); website: www.sama-tv.net	Addounia TV has incited violence against the civilian population in Syria under the former al-Assad regime.	23.9.2011
14.	Cham Holding	Cham Holding Building - Daraa Highway – Ashrafiyat Sahnaya Rif Dimashq – Syria PO Box 9525; Tel: +963 11 9962; +963 11 668 14000; +963 11 673 1044; Fax: +963 11 673 1274; Email: info@chamholding.sy; Website: www.chamholding.sy	Controlled by Rami Makhlouf; second-largest holding company in Syria, benefiting from and supporting the former al-Assad regime.	23.9.2011
15.	El-Tel. Co. (El-Tel. Middle East Company) (a.k.a. Abraj Tech)	Dair Ali Jordan Highway, P.O. Box 13052, Damascus, Syria; Tel: +963 11 2212345; Fax: +963 11 44694450; Email: sales@eltelme.com; Company owner: Maher Dsouki; Websites: www.eltelme.com, www.abrajtec.com	Manufacturing and supplying communication and transmission towers and other equipment for the Syrian army under the former al-Assad regime.	23.9.2011
16.	Ramak Constructions Co.	Dara’a Highway, Damascus, Syria; Tel: +963 11 6858111; Mobile: +963 933 240231	Construction of military barracks, border post barracks and other buildings for army needs under the former al-Assad regime.	23.9.2011

17.	Souruh Company (a.k.a. SOROH Al Cham Company)	Adra Free Zone Area, Damascus, Syria; Tel: +963 11 5327266; Mobile: +963 933 526812; +963 932 878282; Fax: +963 11 5316396; Email: sorohco@gmail.com; Website: http://sites.google.com/site/sorohco	Majority of the shares of the company are owned directly or indirectly by Rami Makhlouf.	23.9.2011
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21.	Centre d’études et de recherches syrien (CERS) (a.k.a. Centre d’Etude et de Recherche Scientifique (CERS); Scientific Studies and Research Centre (SSRC); Centre de Recherche de Kaboun)	Barzeh Street, P.O. Box 4470, Damascus, Syria	Provides support to the Syrian army under the former al-Assad regime for the acquisition of equipment used for the surveillance and repression of demonstrators under the former al-Assad regime. Operating in the chemical weapons proliferation sector, it is the government entity responsible for developing and producing non-conventional weapons, including chemical weapons, and the missiles to deliver them.	1.12.2011

22.	Business Lab	Maysat Square, Al Rasafi Street Bldg. 9, P.O. Box 7155, Damascus, Syria; Tel: +963 11 2725499; Fax: +963 11 2725399	Front company for the acquisition of sensitive equipment by the CERS.	1.12.2011
23.	Industrial Solutions	Baghdad Street 5, P.O. Box 6394, Damascus, Syria; Tel/Fax: +963 11 4471080	Front company for the acquisition of sensitive equipment by the CERS.	1.12.2011

24.	Mechanical Construction Factory (MCF)	P.O. Box 35202, Industrial Zone, Al-Qadam Road, Damascus, Syria Tel.+963 011 5810719; +963 11 4474579; +963 11 5810718; +963 11 5810719; Email:info@metallic-sy.com and shaamco@mail.sy	Front company for the acquisition of sensitive equipment by the CERS.	1.12.2011
25.	Syronics – Syrian Arab Co. for Electronic Industries	Kaboon Street, PO Box 5966, Damascus, Syria; Tel. +963 11 5111352; Fax +963 11 5110117 Email: info@syronics.com.sy	Front company for the acquisition of sensitive equipment by the CERS.	1.12.2011
26.	Handasieh – Organization for Engineering Industries	P.O. Box 5966, Abou Bakr Al-Seddeq St., Damascus, Syria and P.O. Box 2849, Al-Moutanabi Street, Damascus, Syria and P.O. Box 21120, Baramkeh, Damascus, Syria; Tel. + 96311 2121824; +963 11 2121825; +963 11 2131307; Email: g.o.eng.ind@net.sy	Front company for the acquisition of sensitive equipment by the CERS.	1.12.2011
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42.	Ministry of Defence	Umayyad Square, Damascus, Syria Tel: +963 11 7770700	Syrian government branch directly involved in repression under the former al-Assad regime.	26.6.2012
43.	Ministry of Interior	Merjeh Square, Damascus, Syria Tel: +963 11 2219400; +963 11 2219401; +963 11 2220220; +963 11 2210404	Syrian government branch directly involved in repression under the former al-Assad regime.	26.6.2012
44.	Syrian National Security Bureau		Syrian government branch and element of the Syrian Ba’ath Party. Directly involved in repression under the former al-Assad regime. It directed Syrian security forces to use extreme force against demonstrators.	26.6.2012
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48.	Drex Technologies S.A.	Incorporation date: 4.7.2000; Incorporation number: 394678; Director: Rami Makhlouf; Registered agent: Mossack Fonseca & Co (BVI) Ltd	Drex Technologies is wholly owned by Rami Makhlouf, who is listed under Union sanctions for providing financial support to the former al-Assad regime. Rami Makhlouf uses Drex Technologies to facilitate and manage his international financial holdings, including a majority share in SyriaTel, which the Union has previously listed on the grounds that it also provides financial support to the former al-Assad regime.	24.7.2012
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52.	Megatrade	Aleppo Street, P.O. Box 5966, Damascus, Syria; Fax: +963 11 4471081	Acts as a proxy for the Scientific Studies and Research Centre (SSRC), which is listed. Involved in trade in dual use goods prohibited by Union sanctions for the former al-Assad government.	16.10.2012
53.	Expert Partners	Rukn Addin, Saladin Street, Building 5, P.O. Box 7006, Damascus, Syria	Acts as a proxy for the Scientific Studies and Research Centre (SSRC), which is listed. Involved in trade in dual use goods prohibited by Union sanctions for the former al-Assad government.	16.10.2012
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58.	Army Supply Bureau	P.O. Box 3361, Damascus, Syria	Involved in the procurement of military equipment for the former al-Assad regime, and therefore responsible for the violent repression of the civilian population in Syria. Branch of the Syrian Ministry of Defence.	23.7.2014
59.	Industrial Establishment of Defence (a.k.a. Industrial Establishment of Defense (IED); Industrial Establishment for Defence; Defence Factories Establishment; Establissements Industriels de la Defense (EID); Establissement Industrial de la Defence (ETINDE), Coefficient Defense Foundation)	Al Thawraa Street, P.O. Box 2330 Damascus, Syria Or Al-Hameh, Damascus Countryside, P.O. Box 2230, Syria	Involved in the procurement of military equipment for the former al-Assad regime, and therefore responsible for the violent repression of the civilian population in Syria. Branch of the Syrian Ministry of Defence.	23.7.2014
60.	Higher Institute for Applied Sciences and Technology (HIAST) ( ) (a.k.a. Institut Supérieur des Sciences Appliquées et de Technologie (ISSAT))	P.O. Box 31983, Barzeh, Syria	Affiliated to and a subsidiary of the Syrian Scientific Studies and Research Centre (SSRC) which is already designated by the Council. It provides training and support to the SSRC and is therefore responsible for the violent repression of the civilian population under the former al-Assad regime.	23.7.2014
61.	National Standards & Calibration Laboratory (NSCL)	P.O. Box 4470, Damascus, Syria	Affiliated to and a subsidiary of the Syrian Scientific Studies and Research Centre (SSRC) which is already designated by the Council. It provides training and support to the SSRC and is therefore responsible for the violent repression of the civilian population under the former al-Assad regime.	23.7.2014

62.	El Jazireh (a.k.a. Al Jazerra)	Shaheen Building, 2nd floor, Sami el Solh, Beirut, Lebanon; Sector of hydrocarbons	Owned or controlled by Ayman Jaber, therefore associated with a designated person.	23.7.2014
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65.	Organisation for Technological Industries (OTI) (a.k.a. Technical Industries Corporation (TIC))	P.O. Box 11037, Damascus, Syria	Subsidiary of the Syrian Ministry of Defence, which has been designated by the Council. OTI is involved in the production of chemical weapons for the former al-Assad regime. It is therefore responsible for the violent repression of the Syrian population. As a subsidiary of the Ministry of Defence, it is also associated with a designated entity.	7.3.2015

66.	Syrian Company for Information Technology (SCIT)	P.O. Box 11037, Damascus, Syria	Subsidiary of the Organisation for Technological Industries (OTI) and therefore the Syrian Ministry of Defence, which have been designated by the Council. It also works with the Central Bank of Syria which has been designated by the Council. As a subsidiary of OTI and the Ministry of Defence, SCIT is associated with these designated entities.	7.3.2015

67.	Hamsho Trading (a.k.a. Hamsho Group; Hmisho Trading Group; Hmisho Economic Group)	Hamsho Building, 31 Baghdad Street, Damascus, Syria Hamsho group, Damascus countryside – northern road-ring, Hamsho for trading and constructions; Email: info@hamsho-group.com; Tel: 00963 (11) 3227530	Subsidiary of Hamsho International, which has been designated by the Council. As such, Hamsho Trading is associated with a designated entity, Hamsho International. Supports the former al-Assad regime through its subsidiaries, including Syria Steel. Through its subsidiaries it is associated with groups such as the former al-Assad-regime affiliated Shabiha militias.	7.3.2015
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72.	Rawafed Damascus Private Joint Stock Company (a.k.a. Rawafed/Rawafid/Rawafed (Tributary)Damascus Private Joint Stock Company)	Damascus, Syria	A USD 48,3 million joint venture between Damascus Cham Holding, Ramak Development and Humanitarian Projects, Al-Ammar LLC, Timeet Trading LLC (a.k.a. Ultimate Trading Co. Ltd.) and Wings Private JSC. Rawafed supports and/or benefits from the former al-Assad regime, including through its participation in the luxury development Marota City.	21.1.2019
73.	Aman Damascus Joint Stock Company (a.k.a. Aman Damascus JSC)	Damascus, Syria	A USD 18,9 million joint venture between Damascus Cham Holding and Aman Group. Through its participation in the former al-Assad regime-backed luxury development Marota City, Aman Damascus supports and/or benefits from the former al-Assad regime.	21.1.2019
74.	Bunyan Damascus Private Joint Stock Company (a.k.a. Bunyan Damascus Private JSC)	Damascus, Syria	A USD 34,8 million joint venture between Damascus Cham Holding and Apex Development and Projects LLC and Tamayoz LLC. Through its participation in the former al-Assad regime-backed luxury development Marota City, Bunyan Damascus Private Joint Stock Company supports and/or benefits from the former al-Assad regime.	21.1.2019
75.	Mirza	Damascus, Syria	A USD 52,7 million joint venture between Damascus Cham Holding and Talas Group. Through its participation in the luxury development Marota City backed by the former al-Assad regime, Mirza supports and/or benefits from the former al-Assad regime.	21.1.2019
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77.	Al Qatarji Company (a.k.a. Qatarji International Group; Al-Sham and Al-Darwish Company; Qatirji/Khatirji/Katarji/Katerji Group) (مجموعة/شركة قاطرجي)	Type of entity: private company; Business sector: import/export; trucking; supply of oil and commodities; Name of Director/Management: Hussam Al Qatarji, CEO (designated by the Council); Ultimate beneficial owner: Hussam Al Qatarji (designated by the Council); Registered address: Mazzah, Damascus, Syria; Relatives/business associates/entities or partners/links: Arvada/Arfada Petroleum Company JSC	Prominent company operating across multiple sectors of the Syrian economy. By facilitating fuel, arms and ammunition trade between the former al-Assad regime and various actors including ISIL (Da’esh) under the pretext of importing and exporting food items, supporting militias fighting alongside the former al-Assad regime and taking advantage of its ties with the former al-Assad regime to expand its commercial activity, Al Qatarji Company – whose board is headed by designated person Hussam Al Qatarji, a member of the Syrian People’s Assembly – supports and benefits from the former al-Assad regime.	17.2.2020
78.	Damascus Cham Holding Company (a.k.a. Damascus Cham Private Joint Stock Company (القابضة الشام دمشق)	Type of entity: public-owned company under private law; Business sector: real estate development; Name of Director/Management: Adel Anwar al-Olabi, Chairman of the Board of Directors and Governor of Damascus (designated by the Council); Ultimate beneficial owner: Governorate of Damascus; Relatives/business associates/entities or partners/links: Rami Makhlouf (designated by the Council); Samer Foz (designated by the Council); Mazen Tarazi (designated by the Council); Talas Group, owned by businessman Anas Talas (designated by the Council); Khaled al-Zubaidi (designated by the Council).	Damascus Cham Holding Company was established by the former al-Assad regime as the investment arm of the Governorate of Damascus in order to manage the properties of the Governorate of Damascus and implement the Marota City project, a luxurious real estate project based on expropriated land under Decree No 66 and Law No 10 in particular. By managing the implementation of Marota City, Damascus Cham Holding (whose Chairman is the Governor of Damascus) supports and benefits from the former al-Assad regime and provides benefits to businesspeople with close ties to the former al-Assad regime who have struck lucrative deals with this entity through public-private partnerships.	17.2.2020
79.	Velada LLC OOO Велада	Address: Ochakovskoye Shosse, Dom 28, Building 2, Local 3, Room 8, Moscow, 119530, Russian Federation; Date of creation: 29.6. 2015	Velada LLC is a private company that is involved in the oil and gas sector in Syria. In December 2019, the Syrian parliament approved a contract granting Velada LLC the right to develop oil and gas in Syria, including in oilfields in the regime-controlled areas in Northeast Syria and a gas field north of Damascus. Thus, it benefits from or supports the former al-Assad regime.	13.12.2021
80.	Mercury LLC OOO Меркурий	Address: Leninsky Prospekt, Dom 137, Building 1, Local 2, Room 5, Moscow, Russian Federation	Mercury LLC is a private company involved in the oil and gas sector in Syria. In December 2019, the Syrian parliament approved a contract granting Mercury LLC the right to develop oil and gas in Syria, including in oilfields in the regime-controlled areas in Northeast Syria and a gas field in the north of Damascus. Thus, it benefits from or supports the former al-Assad regime.	13.12.2021
81.	Evro Polis LLC OOO Евро Полис	Address: Ulitsa Bratev, Gozozankinykh, Dom 2B, Pomeshchenie 3.1., Krasnogorsk, 143409, Russian Federation; Relatives/Associates: General Petroleum Corp.	Evro Polis LLC is a private company linked to the Wagner Group in Syria, involved in the mining, oil and gas sectors in Syria. Evro Polis LLC is used as a front for the Wagner Group in Syria. It has signed a number of contracts with the former al-Assad regime, through the state-owned General Petroleum Corp., under which it receives 25 % of the proceeds from the production of oil and gas in fields captured by the Wagner Group. Thus, it benefits from or supports the former al-Assad regime.	13.12.2021
82.	Sanad Protection and Security Services (شركة سند للحرسات والخدمات الأمنية)	Type of entity: Limited Liability Company Date of creation: 22 October 2017 Headquarters: Damascus	Sanad Protection and Security Services is a Syrian private security company, established in 2017 and supervised by the Wagner Group in Syria, active in the protection of Russian interests (phosphates, gas and securing oil sites) in Syria. The exploitation of natural resources provides revenues to the former al-Assad regime. In addition, the company is active in the recruitment of Syrian mercenaries to Libya and Ukraine. As such, the company supports the former al-Assad regime and benefits from it.	21.7.2022
83.	Fourth Armoured Division of the Syrian Army الفرقة الرابع	Place of registration: Damascus; Principal place of business: Syrian regime territory in Syria; Associated individuals: Maher al-Assad, Ghassan Belal	The Fourth Armoured Division is one of the most prominent military units of the Syrian army during the former al-Assad regime led by Maher al-Assad and commanded by Ghassan Bilal. The Fourth Armoured Division is responsible for the violent repression of the civilian population. The Fourth Armoured Division also profits form the war economy, especially the trafficking in Captagon. Captagon trade has become a business model led by the former al-Assad regime, enriching the inner circle of the former al-Assad regime and forming its lifeline. Therefore, the Fourth Armoured Division benefits from and supports the former al-Assad regime.	24.4.2023
84.	Neptunus LLC/Neptune LLC company شركة نبتونوس المحدودة المسؤولية نبتونس أوفرسيز المحدودة	Place of registration: Lattakia, Syria; Date of registration: 2017	Neptunus LLC is involved in drug operations in the port of Latakia. Neptunus LLC therefore benefits from and supports the former al-Assad regime. Neptunus LLC was co-founded by Taher Al-Kayali.	24.4.2023
85.	Areen foundation/مؤسسة العرين	Place of registration: Syria; Date of registration: 1999; Principal place of business: Syria; Associated individuals: Asma al-Assad (wife of Bashar al-Assad and Director)	The al-Areen foundation poses as a charitable foundation, but is closely affiliated with former al-Assad regime-affiliated militias. The al-Areen foundation is directed by the former President’s wife, Asma al-Assad. The foundation is channelling aid in line with the policies and priorities of the former al-Assad regime, and therefore benefits from and supports the former al-Assad regime.	24.4.2023
86.	Stroytransgaz/Стройтрансгаз	Other information: Stroytransgaz Group, Stroytransgaz (STG) Logistic, Stroytransgaz (STG) Engineering, STG Engineering	Stroytransgaz is a Russian engineering and construction company operating in Syria, which amongst other things assumed control of Syria’s largest phosphate mines. Stroytransgaz therefore benefits from and supports the former al-Assad regime.	24.4.2023
87.	Gecopham, the General Company for Phosphate and Mines الشركة العامة للفوسفات و المناجم	Address: Palmyra Road, Homs, Syrian Arabic Republic; Phone: 00963312751122; Email: info@gecopham.sy; General Manager: Younes Ramadan	Gecopham is controlled by the Syrian Ministry of Petroleum and Mineral Resources and provides financial support to the former al-Assad regime. It therefore supports the former al-Assad regime.	24.4.2023
88.	Al-Jabal Security and Protection LLC شركة الجبل لخدمات الحماية والحراسة	Address: F6XR+495, Malek Bin Rabeaa, Damascus, Syria; Type of entity: Limited Liability Company; Place of registration: Damascus; Date of registration: 19.10.2017; Principal place of business: Damascus, Syria; Associated individuals: Osama Mohammad al-Maliki	Al-Jabal Security and Protection LLC is owned and managed by Osama al-Maliki. Al-Jabal Security and Protection LLC acts as a shell company to allow for the continuation of activities of the Saraya al-Areen 313 militia, a regime-affiliated militia. Al-Jabal Security and Protection LLC therefore benefits from and supports the former al-Assad regime.	24.4.2023
89.	Castle for Security and Protection LLC شركة القلعة للحماية والحراسة والخدمات الأمني a.k.a. Castle Security and Protection LLC, Citadel for Security and Protection	Address: Saraya Roundabout, Western Villas, Mazze, Damascus, Syria; Type of entity: Limited Liability Company; Place of registration: Damascus, Syria; Date of registration: 18.10.2017; Principal place of business: Damascus, Syria; Other information: Sector: Militia turned Security Company; Phone Number: +963116119331; +963943800808	Castle for Security and Protection LLC is a private company, which acts as a shell company for the Fourth Division of the Syrian Arab Army, which is led by Maher al-Assad. Castle for Security is involved also in the trafficking of narcotics. The Captagon trade has become a business model led by the former al-Assad regime, enriching the inner circle of the former al-Assad regime and forming its lifeline. It therefore benefits from and supports the former al-Assad regime.	24.4.2023
90.	Aman for Protection and Security LLC شركة أمان للحماية والحراسة الأمنية	Address: Damascus Countryside; Type of entity: Limited Liability Company; Place of registration: Damascus Countryside; Date of registration: 10.10.2018; Registration number: 2906; Principal place of business: Damascus Countryside, Syria; Associated individuals: Muhammad Abdo Assad	Aman for Protection and Security LLC is a private security company, which acts as a shell company for the Hosn al-Watan milita, founded by Muhammad Abdo Assaad. It therefore benefits from and supports the former al-Assad regime.	24.4.2023
91.	Al-Dj Group (a.k.a. ALDJ)	Place of registration: Damascus, Syria; Principal place of business: Syria	Al-Dj Group is a Syrian business entity, owned and managed by Mahmoud al-Dj. As a holding company it owns and operates the Freebird Travel Agency, an agent for Cham Wings Airlines, which is conducting frequent flights between Syria and Libya, smuggling mercenaries, and narcotics. Al-Dj Group is further associated with Al-Tair Company, which is also owned by Mahmoud al-Dj. Through this scheme of business relations, in which Al-Dj Group plays a central role, cargo shipping and flights are used for illicit transactions between regime-affiliated persons and entities in Syria and Eastern Libya, including narcotics. Al-Dj Group’s activities benefit the former al-Assad regime and support it in accessing illicit revenues.	22.1.2024
92.	Cham Wings	Place of registration: Damascus, Syria; Principal place of business: Damascus, Syria	Cham Wings Airlines is a Syrian business entity which is owned by Muhammad Issam Shammout. Also, Cham Wings uses its flights to engage in the transfer of Syrian mercenaries, arms trade, narcotics trafficking, and money laundering, which supports the activities of the former al-Assad regime. As the only private airline in Syria, Cham Wings is therefore benefiting from, and providing support to the former al-Assad regime.	22.1.2024
93.	Freebird Travel Agency	Place of registration: Syria, Dubai; Principal place of business: Damascus, Syria	The Freebird Travel Agency is a Syrian business entity owned and operated by Al-Dj Group, which in turn is owned and managed by Mahmoud al-Dj. Freebird serves as principal agent for Cham Wings Airlines, and thereby benefits from and provides support to the former al-Assad regime.	22.1.2024
94.	Iloma Investment Private JSC (a.k.a. Eloma)	Place of registration: Damascus, Syria; Date of registration: 2023; Principal place of business: Damascus, Syria	Iloma Investment Private JSC has been established at the beginning of 2023 to take over almost half of the ownership of Damascus airport. Iloma is a front for the Assad family and part of the former al-Assad regime’s efforts to personally gain from manipulation of the economy. Therefore, Iloma is supporting and benefiting from the former al-Assad regime.	22.1.2024.
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ANNEX III

Websites for information on the competent authorities and address for notifications to the European Commission

BELGIUM

https://diplomatie.belgium.be/en/policy/policy_areas/peace_and_security/sanctions

BULGARIA

https://www.mfa.bg/en/EU-sanctions

CZECHIA

www.financnianalytickyurad.cz/mezinarodni-sankce.html

DENMARK

https://um.dk/udenrigspolitik/sanktioner/ansvarlige-myndigheder

GERMANY

https://www.bmwi.de/Redaktion/DE/Artikel/Aussenwirtschaft/embargos-aussenwirtschaftsrecht.html

ESTONIA

https://vm.ee/sanktsioonid-ekspordi-ja-relvastuskontroll/rahvusvahelised-sanktsioonid

IRELAND

https://www.dfa.ie/our-role-policies/ireland-in-the-eu/eu-restrictive-measures/

GREECE

http://www.mfa.gr/en/foreign-policy/global-issues/international-sanctions.html

SPAIN

https://www.exteriores.gob.es/es/PoliticaExterior/Paginas/SancionesInternacionales.aspx

FRANCE

http://www.diplomatie.gouv.fr/fr/autorites-sanctions/

CROATIA

https://mvep.gov.hr/vanjska-politika/medjunarodne-mjere-ogranicavanja/22955

ITALY

https://www.esteri.it/it/politica-estera-e-cooperazione-allo-sviluppo/politica_europea/misure_deroghe/

CYPRUS

https://mfa.gov.cy/themes/

LATVIA

https://www.fid.gov.lv/en

LITHUANIA

https://www.urm.lt/en/lithuania-in-the-region-and-the-world/lithuanias-security-policy/international-sanctions/997

LUXEMBOURG

https://maee.gouvernement.lu/fr/directions-du-ministere/affaires-europeennes/organisations-economiques-int/mesures-restrictives.html

HUNGARY

https://kormany.hu/kulgazdasagi-es-kulugyminiszterium/ensz-eu-szankcios-tajekoztato

MALTA

https://smb.gov.mt/

NETHERLANDS

https://www.rijksoverheid.nl/onderwerpen/internationale-sancties

AUSTRIA

https://www.bmeia.gv.at/themen/aussenpolitik/europa/eu-sanktionen-nationale-behoerden/

POLAND

https://www.gov.pl/web/dyplomacja/sankcje-miedzynarodowe

https://www.gov.pl/web/diplomacy/international-sanctions

PORTUGAL

https://portaldiplomatico.mne.gov.pt/politica-externa/medidas-restritivas

ROMANIA

http://www.mae.ro/node/1548

SLOVENIA

http://www.mzz.gov.si/si/omejevalni_ukrepi

SLOVAKIA

https://www.mzv.sk/europske_zalezitosti/europske_politiky-sankcie_eu

FINLAND

https://um.fi/pakotteet

SWEDEN

https://www.regeringen.se/sanktioner

Address for notifications to the European Commission:

European Commission

Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA)

Rue de Spa 2/Spastraat 2

B-1049 Bruxelles/Brussel,

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ANNEX V

EQUIPMENT, TECHNOLOGY AND SOFTWARE REFERRED TO IN ARTICLE 4

General Note

Notwithstanding the contents of this Annex, it shall not apply to:

(a) equipment, technology or software which are specified in Annex I to Council Regulation (EC) 428/2009 (¹⁰) or the Common Military List; or

(b) software which is designed for installation by the user without further substantial support by the supplier and which is generally available to the public by being sold from stock at retail selling points, without restriction, by means of: (i) over the counter transactions; (ii) mail order transactions; (iii) electronic transactions; or (iv) telephone order transactions; or

The categories A, B, C, D and E refer to the categories referred to in Regulation (EC) No 428/2009.

The ‘equipment, technology and software’ referred to in Article 4 is:

A. List of equipment — Deep Packet Inspection equipment — Network Interception equipment including Interception Management Equipment (IMS) and Data Retention Link Intelligence equipment — Radio Frequency monitoring equipment — Network and Satellite jamming equipment — Remote Infection equipment — Speaker recognition/processing equipment — IMSI (¹¹), MSISDN (¹²), IMEI (¹³), TMSI (¹⁴) interception and monitoring equipment — Tactical SMS (¹⁵)/GSM (¹⁶)/GPS (¹⁷)/GPRS (¹⁸)/UMTS (¹⁹)/CDMA (²⁰)/PSTN (²¹) interception and monitoring equipment — DHCP (²²)/SMTP (²³),GTP (²⁴) information interception and monitoring equipment — Pattern Recognition and Pattern Profiling equipment — Remote Forensics equipment — Semantic Processing Engine equipment — WEP and WPA code breaking equipment — Interception equipment for VoIP proprietary and standard protocol

B. Not used

C. Not used

D. ‘Software’ for the ‘development’, ‘production’ or ‘use’ of the equipment specified in A above.

E. ‘Technology’ for the ‘development’, ‘production’ or ‘use’ of the equipment specified in A above.

Equipment, technology and software falling within these categories is within the scope of this Annex only to the extent that it falls within the general description ‘internet, telephone and satellite communications interception and monitoring systems’.

For the purpose of this Annex ‘monitoring’ means acquisition, extraction, decoding, recording, processing, analysis and archiving call content or network data.

ANNEX IX

LIST OF EQUIPMENT, GOODS AND TECHNOLOGY REFERRED TO IN ARTICLE 2b

The list set out in this Annex shall not include products identified as consumer goods packaged for retail sale for personal use or packaged for individual use, with the exception of isopropanol.

Introductory Notes

1.Unless otherwise stated, reference numbers used in the column below entitled ‘Description’ refer to the descriptions of dual-use items set out in Annex I to Regulation (EC) No 428/2009.

2.A reference number in the column below entitled ‘Related item from Annex I to Regulation (EC) No 428/2009’ means that the characteristics of the item described in the ‘Description’ column lie outside the parameters set out in the description of the dual-use entry referred to.

3.Definitions of terms between ‘single quotation marks’ are given in a technical note to the relevant item.

4.Definitions of terms between ‘double quotation marks’ can be found in Annex I to Regulation (EC) No 428/2009.

General Notes

1.The object of the controls contained in this Annex should not be defeated by the export of any non-controlled goods (including plant) containing one or more controlled components when the controlled component or components is/are the principal element of the goods and can feasibly be removed or used for other purposes.

NB: In judging whether the controlled component or components is/are to be considered the principal element, it is necessary to weigh the factors of quantity, value and technological know-how involved and other special circumstances which might establish the controlled component or components as the principal element of the goods being procured.

2.The items specified in this Annex include both new and used goods.

General Technology Note (GTN)

(To be read in conjunction with Section B of this Annex)

1.The sale, supply, transfer or export of ‘technology’ which is ‘required’ for the ‘development’, ‘production’ or ‘use’ of goods the sale, supply, transfer or export of which is controlled in Section IX.A of this Annex, is controlled in accordance with the provisions of Section B.

2.The ‘technology’‘required’ for the ‘development’, ‘production’ or ‘use’ of goods under control remains under control even when it is applicable to non-controlled goods.

3.Controls do not apply to that ‘technology’ which is the minimum necessary for the installation, operation, maintenance (checking) and repair of those goods which are not controlled or the export of which has been authorised in accordance with this Regulation.

4.Controls on ‘technology’ transfer do not apply to information ‘in the public domain’, to ‘basic scientific research’ or to the minimum necessary information for patent applications.

IX.A1. Materials, chemicals, ‘micro-organisms’ and ‘toxins’

No	Description	Related item from Annex I to Regulation (EC) No 428/2009
IX.A1.001	Chemicals at 95 % concentration or greater, as follows: Tributylphosphite, (CAS 102-85-2) Isocyanatomethane, (CAS 624-83-9) Quinaldine, (CAS 91-63-4) 2-bromochloroethane, (CAS 107-04-0)
IX.A1.002	Chemicals at 95 % concentration or greater, as follows: Benzil, (CAS 134-81-6) Diethylamine, (CAS 109-89-7) Diethyl ether, (CAS 60-29-7) Dimethyl ether, (CAS 115-10-6) Dimethylaminoethanol, (CAS 108-01-0)
IX.A1.003	Chemicals at 95 % concentration or greater, as follows: 2-methoxyethanol, (CAS 109-86-4) Butyrylcholinesterase (BCHE) Diethylenetriamine, (CAS 111-40-0) Dichloromethane, (CAS 75-09-2) Dimethylanaline, (CAS 121-69-7) Ethyl bromide, (CAS 74-96-4) Ethyl chloride, (CAS 75-00-3) Ethylamine, (CAS 75-04-7) Hexamine, (CAS 100-97-0) Isopropyl bromide, (CAS 75-26-3) Isopropyl ether, (CAS 108-20-3) Methylamine, (CAS 74-89-5) Methyl bromide, (CAS 74-83-9) Monoisopropylamine, (CAS 75-31-0) Obidoxime chloride, (CAS 114-90-9) Potassium bromide, (CAS 7758-02-3) Pyridine, (CAS 110-86-1) Pyridostigmine bromide, (CAS 101-26-8) Sodium bromide, (CAS 7647-15-6) Sodium metal, (CAS 7440-23-5) Tributylamine, (CAS 102-82-9) Triethylamine, (CAS 121-44-8) Trimethylamine, (CAS 75-50-3)

IX.A1.004	Separate chemically defined compounds according to Note 1 to Chapters 28 and 29 of the Combined Nomenclature (¹), at 90 % concentration or greater, unless otherwise indicated, as follows: Acetone, (CAS RN 67-64-1) (CN code 2914 11 00 ) Acetylene, (CAS RN 74-86-2) (CN code 2901 29 00 ) Ammonia, (CAS RN 7664-41-7) (CN code 2814 10 00 ) Antimony, (CAS RN 7440-36-0) (heading 8110 ) Benzaldehyde, (CAS RN 100-52-7) (CN code 2912 21 00 ) Benzoin, (CAS RN 119-53-9) (CN code 2914 40 90 ) 1-Butanol, (CAS RN 71-36-3) (CN code 2905 13 00 ) 2-Butanol, (CAS RN 78-92-2) (CN code 2905 14 90 ) Iso-Butanol, (CAS RN 78-83-1) (CN code 2905 14 90 ) Tert-Butanol, (CAS RN 75-65-0) (CN code 2905 14 10 ) Calcium carbide, (CAS RN 75-20-7) (CN code 2849 10 00 ) Carbon monoxide, (CAS RN 630-08-0) (CN code 2811 29 90 ) Chlorine, (CAS RN 7782-50-5) (CN code 2801 10 00 ) Cyclohexanol, (CAS RN 108-93-0) (CN code 2906 12 00 ) Dicyclohexylamine (DCA), (CAS RN 101-83-7) (CN code 2921 30 99 ) Ethanol, (CAS RN 64-17-5) (CN code 2207 10 00 ) Ethylene, (CAS RN 74-85-1) (CN code 2901 21 00 ) Ethylene oxide, (CAS RN 75-21-8) (CN code 2910 10 00 ) Fluoroapatite, (CAS RN 1306-05-4) (CN code 2835 39 00 ) Hydrogen chloride, (CAS RN 7647-01-0) (CN code 2806 10 00 ) Hydrogen sulfide, (CAS RN 7783-06-4) (CN code 2811 19 80 ) Isopropanol, 95 % concentration or greater, (CAS RN 67-63-0) (CN code 2905 12 00 ) Mandelic acid, (CAS RN 90-64-2) (CN code 2918 19 98 ) Methanol, (CAS RN 67-56-1) (CN code 2905 11 00 ) Methyl chloride, (CAS RN 74-87-3) (CN code 2903 11 00 ) Methyl iodide, (CAS RN 74-88-4) (CN code 2903 39 90 ) Methyl mercaptan, (CAS RN 74-93-1) (CN code 2930 90 99 ) Monoethyleneglycol, (CAS RN 107-21-1) (CN code 2905 31 00 ) Oxalyl chloride, (CAS RN 79-37-8) (CN code 2917 19 90 ) Potassium sulphide, (CAS RN 1312-73-8) (CN code 2830 90 85 ) Potassium thiocyanate (KSCN), (CAS RN 333-20-0) (CN code 2842 90 80 ) Sodium hypochlorite, (CAS RN 7681-52-9) (CN code 2828 90 00 ) Sulphur, (CAS RN 7704-34-9) (CN code 2802 00 00 ) Sulphur dioxide, (CAS RN 7446-09-5) (CN code 2811 29 05 ) Sulphur trioxide, (CAS RN 7446-11-9) (CN code 2811 29 10 ) Thiophosphoryl chloride, (CAS RN 3982-91-0) (CN code 2853 00 90 ) Tri-isobutyl phosphite, (CAS RN 1606-96-8) (CN code 2920 90 85 ) White/yellow phosphorus, (CAS RN 12185-10-3, 7723-14-0) (CN code 2804 70 00 )

(¹) As set out in the Commission Implementing Regulation (EU) No 927/2012 of 9 October 2012 amending Annex I to Council Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and on the Common Customs Tariff (OJ L 304, 31.10.2012, p. 1).

IX.A2. Materials Processing

No	Description	Related item from Annex I to Regulation (EC) No 428/2009
IX.A2.001	Floor-mounted fume hoods (walk-in-style) with a minimum nominal width of 2,5 meters.
IX.A2.002	Full face-mask air-purifying and air-supplying respirators other than those specified in 1A004 or 2B352f1.	1A004.a
IX.A2.003	Class II biological safety cabinets or isolators with similar performance standards.	2B352.f.2
IX.A2.004	Batch centrifuges with a rotor capacity of 4 litres or greater, usable with biological materials.
IX.A2.005	Fermenters capable of cultivation of pathogenic ‘micro-organisms’, viruses or for toxin production, without the propagation of aerosols, having a capacity of 5 litres or more but less than 20 litres. Technical Note: Fermenters include bioreactors, chemostats and continuous-flow systems.	2B352.b
IX.A2.007	Conventional or turbulent air-flow clean-air rooms and self contained fan-HEPA or ULPA filter units that may be used for P3 or P4 (BSL 3, BSL 4, L3, L4) containments facilities.	2B352.a
IX.A2.008	Chemical manufacturing facilities, equipment and components, other than those specified in 2B350 or A2.009 as follows: a. Reaction vessels or reactors, with or without agitators, with total internal (geometric) volume greater than 0,1 m³ (100 litres) and less than 20 m³ (20 000 litres), where all surfaces that come in direct contact with the fluid(s) being processed or contained are made from the following materials: 1. Stainless steels with more than or equal to 10,5 % chromium and less than or equal to 1,2 % carbon; b. Agitators for use in reaction vessels or reactors specified in 2B350.a.; where all surfaces that come in direct contact with the fluid(s) being processed or contained are made from the following materials: 1. Stainless steels with more than or equal to 10,5 % chromium and less than or equal to 1,2 % carbon; c. Storage tanks, containers or receivers with a total internal (geometric) volume greater than 0,1 m³ (100 litres) where all surfaces that come in direct contact with the fluid(s) being processed or contained are made from the following materials: 1. Stainless steels with more than or equal to 10,5 % chromium and less than or equal to 1,2 % carbon; d. Heat exchangers or condensers with a heat transfer surface area greater than 0,05 m², and less than 30 m²; and tubes, plates, coils or blocks (cores) designed for such heat exchangers or condensers, where all surfaces that come in direct contact with the fluid(s) being processed are made from the following materials: 1. Stainless steels with more than or equal to 10,5 % chromium and less than or equal to 1,2 % carbon; Technical Note: The materials used for gaskets and seals and other implementation of sealing functions do not determine the control status of the heat exchanger. e. Distillation or absorption columns of internal diameter greater than 0,1 m; where all surfaces that come in direct contact with the fluid(s) being processed are made from the following materials: 1. Stainless steels with more than or equal to 10,5 % chromium and less than or equal to 1,2 % carbon; f. Valves with ‘nominal sizes’ greater than 10 mm and casings (valve bodies) designed for such valves where all surfaces that come in direct contact with the fluid(s) being processed or contained are made from the following materials: 1. Stainless steels with more than or equal to 10,5 % chromium and less than or equal to 1,2 % carbon; Technical Note: 1. The materials used for gaskets and seals and other implementation of sealing functions do not determine the control status of the valve. 2. The ‘nominal size’ is defined as the smaller of the inlet and outlet diameters. g. Multiple-seal and seal-less pumps, with manufacturer’s specified maximum flow-rate greater than 0,6 m³/hour, in which all surfaces that come in direct contact with the chemical(s) being processed are made from the following materials: 1. Stainless steels with more than or equal to 10,5 % chromium and less than or equal to 1,2 % carbon. h. Vacuum pumps with a manufacturer’s specified maximum flow-rate greater than 1 m³/h (under standard temperature (273 K (0 °C)) and pressure (101,3 kPa) conditions), and casings (pump bodies) and preformed casing-liners, impellers, rotors and jet pump nozzles designed for such pumps, in which all surfaces that come into direct contact with the chemicals being processed are made from any of the following materials: 1. ‘Alloys’ with more than 25 % nickel and 20 % chromium by weight; 2. Ceramics; 3. ‘Ferrosilicon’; 4. Fluoropolymers (polymeric or elastomeric materials with more than 35 % fluorine by weight); 5. Glass (including vitrified or enamelled coatings or glass lining); 6. Graphite or ‘carbon graphite’; 7. Nickel or ‘alloys’ with more than 40 % nickel by weight; 8. Stainless steel with 20 % nickel and 19 % chromium or more by weight; 9. Tantalum or tantalum ‘alloys’; 10. Titanium or titanium ‘alloys’; 11. Zirconium or zirconium ‘alloys’; or 12. Niobium (columbium) or niobium ‘alloys’. Technical Notes: 1. The materials used for diaphragms or gaskets and seals and other implementation of sealing functions do not determine the status of control of the pump. 2. ‘Carbon graphite’ is a composition consisting of amorphous carbon and graphite, in which the graphite content is 8 % or more by weight. 3. ‘Ferrosilicons’ are silicon iron alloys with more than 8 % silicon by weight or more. For the listed materials in the above entries, the term ‘alloy’ when not accompanied by a specific elemental concentration is understood as identifying those alloys where the identified metal is present in a higher percentage by weight than any other element.	2B350.a-e 2B350.g 2B350.i
IX.A2.009	Chemical manufacturing facilities, equipment and components, other than specified in 2B350 or A2.008 as follows: Reaction vessels or reactors, with or without agitators, with a total internal (geometric) volume greater than 0,1 m³ (100 litres) and less than 20 m³ (20 000 litres) where all surfaces that come in direct contact with the fluid(s) being processed or contained are made from the following materials: Stainless steel with 20 % nickel and 19 % chromium or more by weight; Agitators for use in reaction vessels or reactors specified in a. where all surfaces that come in direct contact with the fluid(s) being processed or contained are made from the following materials: Stainless steel with 20 % nickel and 19 % chromium or more by weight; Storage tanks, containers or receivers with a total internal (geometric) volume greater than 0,1 m³ (100 litres) where all surfaces that come in direct contact with the fluid(s) being processed or contained are made from the following materials: Stainless steel with 20 % nickel and 19 % chromium or more by weight; Heat exchangers or condensers with a heat transfer surface area greater than 0,05 m², and less than 30 m²; and tubes, plates, coils or blocks (cores) designed for such heat exchangers or condensers, where all surfaces that come in direct contact with the fluid(s) being processed are made from the following materials: Stainless steel with 20 % nickel and 19 % chromium or more by weight; Technical Note: The materials used for gaskets and seals and other implementation of sealing functions do not determine the control status of the heat exchanger. Distillation or absorption columns of internal diameter greater than 0,1 m; and liquid distributors, vapour distributors or liquid collectors, in which all surfaces that come in direct contact with the chemical(s) being processed are made from the following materials: Stainless steel with 20 % nickel and 19 % chromium or more by weight; Valves having a nominal diameter of 10 mm or more, and casings (valve bodies), balls or plugs designed for such valves, in which all surfaces that come in direct contact with the chemical(s) being processed or contained are made from the following materials: Stainless steel with 20 % nickel and 19 % chromium or more by weight; Technical note: The ‘nominal size’ is defined as the smaller of the inlet and outlet port diameters. Multiple-seal and seal-less pumps with manufacturer’s specified maximum flow-rate greater than 0,6 m³/hour (measured under standard temperature (273 K or 0 °C) and pressure (101,3 kPa) conditions); and casings (pump bodies), preformed casing liners, impellers, rotors or jet pump nozzles designed for such pumps, in which all surfaces that come in direct contact with the chemical(s) being processed are made from any of the following materials: Ceramics; Ferrosilicon (silicon iron alloys with more than 8 % silicon by weight or more); Stainless steel with 20 % nickel and 19 % chromium or more by weight; Technical Notes: The materials used for diaphragms or gaskets and seals and other implementation of sealing functions do not determine the control status of the pump. For the listed materials in the above entries, the term ‘alloy’ when not accompanied by a specific elemental concentration is understood as identifying those alloys where the identified metal is present in a higher percentage by weight than any other element.

IX.A2.010	Equipment Laboratory equipment, including parts and accessories for such equipment, for the (destructive or non-destructive) analysis or detection of chemical substances, with the exception of equipment, including parts or accessories, specifically designed for medical use.

B. TECHNOLOGY

No	Description	Related item from Annex I to Regulation (EC) No 428/2009
IX.B.001	‘Technology’ required for the ‘development’, ‘production’ or ‘use’ of the items in Section IX.A. Technical Note: The term ‘technology’ includes ‘software’.

ANNEX XI

List of categories of goods referred to in Article 11c

ex CN code	Product description
9705 00 00	1. Archaeological objects more than 100 years old which are the products of:
9706 00 00	— excavations and finds on land or under water
— archaeological sites
— archaeological collections
9705 00 00 9706 00 00	2. Elements forming an integral part of artistic, historical or religious monuments which have been dismembered, of an age exceeding 100 years
9701	3. Pictures and paintings, other than those included in category 4 or 5, executed entirely by hand in any medium and on any material (¹)
9701	4. Water-colours, gouaches and pastels executed entirely by hand on any material (¹)
6914 9701	5. Mosaics in any material executed entirely by hand, other than those falling in category 1 or 2, and drawings in any medium executed entirely by hand on any material (¹)
Chapter 49 9702 00 00 8442 50 80	6. Original engravings, prints, serigraphs and lithographs with their respective plates and original posters (¹)
9703 00 00	7. Original sculptures or statuary and copies produced by the same process as the original (¹) other than those in category 1
3704 3705 3706 4911 91 00	8. Photographs, films and negatives thereof (¹)
9702 00 00 9706 00 00 4901 10 00 4901 99 00 4904 00 00 4905 91 00 4905 99 00 4906 00 00	9. Incunabula and manuscripts, including maps and musical scores, singly or in collections (¹)
9705 00 00 9706 00 00	10. Books more than 100 years old, singly or in collections
9706 00 00	11. Printed maps more than 200 years old
3704 3705 3706 4901 4906 9705 00 00 9706 00 00	12. Archives, and any elements thereof, of any kind or any medium which are more than 50 years old
9705 00 00	13. (a) Collections (²) and specimens from zoological, botanical, mineralogical or anatomical collections;
9705 00 00	(b) Collections (²) of historical, palaeontological, ethnographic or numismatic interest
9705 00 00 Chapters 86-89	14. Means of transport more than 75 years old
	15. Any other antique items not included in categories 1 to 14
	(a) between 50 and 100 years old:
Chapter 95	— toys, games
7013	— glassware
7114	— articles of goldsmiths' or silversmiths' wares
Chapter 94	— furniture
Chapter 90	— optical, photographic or cinematographic apparatus
Chapter 92	— musical instruments
Chapter 91	— clocks and watches and parts thereof
Chapter 44	— articles of wood
Chapter 69	— pottery
5805 00 00	— tapestries
Chapter 57	— carpets
4814	— wallpaper
Chapter 93	— arms
9706 00 00	(b) more than 100 years old.
(¹) Which are more than 50 years old and do not belong to their originators. (²) As defined by the Court of Justice in its judgment in Case 252/84 as follows: 'Collectors' pieces within the meaning of heading No 97.05 of the Common Customs Tariff are articles which possess the requisite characteristics for inclusion in a collection, that is to say, articles which are relatively rare, are not normally used for their original purpose, are the subject of special transactions outside the normal trade in similar utility articles and are of high value.

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